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STIPULATION AND [PROPOSED] ORDER BETWEEN PARTIES FOR CONTINUANCE OF SET DATES, INCLUDING TRIAL; 

TELEPHONIC APPEARANCE BY DEFENDANT AT SETTLEMENT CONFERENCE

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ROBERT M. YOUNG, Jr. (#063297) 

Email: robert.young@wilsonelser.com 

SHERIDA A. STROBLE (#212707) 

Email: sherry.stroble@wilsonelser.com 

WILSON, ELSER, MOSKOWITZ, 

EDELMAN & DICKER LLP

555 So. Flower Street, Suite 2900 

Los Angeles, California 90071 

Telephone: (213) 443-5100 

Facsimile: (213) 443-5101 

Attorneys for Defendant 

THE PRUDENTIAL INSURANCE COMPANY OF 

AMERICA, 

THE UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

ALFRED J. ANTONINI, 

Plaintiff, 

v. 

THE PRUDENTIAL INSURANCE 

COMPANY OF AMERICA; THE 

PRUDENTIAL WELFARE BENEFITS 

PLAN; THE PRUDENTIAL RETIREMENT 

PLAN, 

Defendants. 

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Case No.: CIV. 04-0505 WBS KJM -PS 

The Hon. William B. Shubb 

STIPULATION AND [PROPOSED] 

ORDER BETWEEN PARTIES FOR 

CONTINUANCE OF SET DATES, 

INCLUDING TRIAL; TELEPHONIC 

APPEARANCE BY DEFENDANT AT 

SETTLEMENT CONFERENCE 

IT IS HEREBY STIPULATED TO, by and between plaintiff, ALFRED J. ANTONINI, 

representing himself, and defendant, PRUDENTIAL INSURANCE COMPANY OF 

AMERICA, by and through its attorney of record, Sherida A. Stroble of Wilson, Elser, 

Moskowitz, Edelman & Dicker LLP, that all dates previously set by this court, including trial 

dates and motion cut-off dates, be continued for a period of 60 days or more, to permit the pro 

se Plaintiff’s potential new counsel to review the extensive Administrative Record and to permit 

the parties to engage in meaningful settlement negotiations. The parties have agreed to attend a 

settlement conference with a court-appointed judicial officer in or about early January, 2007. 

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STIPULATION AND [PROPOSED] ORDER BETWEEN PARTIES FOR CONTINUANCE OF SET DATES, INCLUDING TRIAL; 

TELEPHONIC APPEARANCE BY DEFENDANT AT SETTLEMENT CONFERENCE

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This matter is a claim for benefits under the 1974 ERISA statute. The parties request a 

further continuance to allow this pro se Plaintiff’s potential new counsel time to review the 

extensive Administrative Records, as well as for the parties to attempt resolution, once Plaintiff 

retains counsel, before additional time and expense are expended in trial briefs or further 

litigation. 

The parties have previously requested three continuances. However, due to the breadth of 

the record (the Plaintiff’s employment ended effective January 4, 1980), the fact that Plaintiff 

has been proceeding without an attorney, and the fact that Plaintiff has counsel reviewing his 

case for prospective representation, the Parties request an additional 60 days beyond the current 

December 5, 2006, trial date, as well as the appointment of a court settlement conference officer 

for a settlement conference in January, 2007. 

This request is made in good faith. 

Specifically, the parties propose the following dates, or any dates thereafter that 

accommodate the Court’s calendar, which reflect a continuance period of 60 days or more, to 

accommodate plaintiff’s efforts to obtain counsel and the parties’ efforts at informal resolution: 

December 15, 2006 Cut-off date for Filing Motions 

January 19, 2007 L/D for Settlement Conference 

February 8, 2007 Pre-trial Conference 

February 15, 2007 Trial 

Dated: September 27, 2006 WILSON, ELSER, MOSKOWITZ, 

EDELMAN & DICKER LLP 

By: /s/Sherida A. Stroble 

Robert M. Young, Jr. 

Attorneys for Defendant 

THE PRUDENTIAL INSURANCE 

COMPANY OF AMERICA 

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STIPULATION AND [PROPOSED] ORDER BETWEEN PARTIES FOR CONTINUANCE OF SET DATES, INCLUDING TRIAL; 

TELEPHONIC APPEARANCE BY DEFENDANT AT SETTLEMENT CONFERENCE

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Dated: September 26, 2006 ALFRED J. ANONTINI 

By: /s/ Alfred J. Antonini 

Plaintiff 

ORDER

 The court appointed settlement conference officer is Judge Kimberly J. Mueller. The 

Settlement Conference deadline is January 26, 2007. The Motion Cut-off date for filing of 

motions is December 15, 2006. The Pretrial Conference date is continued to February 12, 2007 

at 10:00 a.m. The Trial date is continued to February 27, 2007 at 9:00 a.m.

IT IS SO ORDERED. 

Dated: September 28, 2006 

 

 

PROOF OF SERVICE 

STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

I am employed in the County of Los Angeles, State of California, by WILSON, ELSER, 

MOSKOWITZ, EDELMAN & DICKER LLP and am over the age of 18 and not a party to the 

within action. My business address is 555 South Flower Street, 29th Floor, Los Angeles, 

California 90071. 

On September 27, 2006, I served the foregoing document described as STIPULATION 

AND [PROPOSED] ORDER BETWEEN PARTIES FOR CONTINUANCE OF SET 

DATES, INCLUDING TRIAL; TELEPHONIC APPEARANCE BY DEFENDANT AT 

SETTLEMENT CONFERENCE on all interested parties, through their respective attorneys of 

record in this action, by placing a true copy thereof enclosed in a sealed envelope addressed as 

follows: 

ALFRED J. ANTONINI 

P.O. Box 0090 

Hayward, California 94543 

-or22572 Main Street 

Hayward, California 94541 

Plaintiff, In Pro Per 

Telephone: (510) 881-4981 

Facsimile: (510) 881-1647 

aainvestments@sbcglobal.net

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STIPULATION AND [PROPOSED] ORDER BETWEEN PARTIES FOR CONTINUANCE OF SET DATES, INCLUDING TRIAL; 

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[X] (BY MAIL) I caused such envelope(s) fully prepaid to be placed in the United 

States Mail at Los Angeles, California. I am “readily familiar” with the firm’s practice of 

collection and processing correspondence or mailing. Under that practice it would be deposited 

with the U.S. postal service on that same day with postage thereon fully prepaid at Los Angeles, 

California in the ordinary course of business. I am aware that on motion of the party served, 

service is presumed invalid if postal cancellation date or postage meter date is more than one day 

after date of deposit for mailing in affidavit. 

[] (BY FACSIMILE) I caused said document(s) to be telephonically transmitted to 

each addressee’s telecopier (Fax) number as noted. 

[X] (Federal) I declare that I am employed in the office of a member of the bar of this 

court at whose direction the service was made. 

Executed on September 27, 2006, at Los Angeles, California. 

 ___/s/ERIKA FACUNDO __________ 

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